Data security tips for healthcare organizations
Posted on 09 January 2013.
Itís that time of year when everyone wants to be healthier. Eat better. Lose weight. Manage stress. Save money. These rank as peoplesí top New Yearís resolutions.


The same holds true for healthcare organizations nationwide. They want and need to protect against the organizational and financial stresses of data breachesówhich have become an everyday disasteróaccording to a recent report issued by Ponemon Institute.

The Third Annual Benchmark Study on Patient Privacy & Data Security reports that data breaches in healthcare are growing; insider negligence is the root cause; and mobile devices pose threats to patientsí protected health information (PHI).

Despite the fact that 94 percent of healthcare organizations surveyed suffered data breaches, data breaches donít have to be disastrous if organizations take steps to operationalize pre-breach and post-breach processes to better protect patient data and minimize breach impact.

Here are 11 tips for a healthier organizationómeant to be kept longer than peoplesí typical New Yearís resolutions:

1. Establish mobile device and Bring Your Own Device (BYOD) policies that include technical controls and employee and management procedures. - Rick Kam, CIPP/US, president and co-founder, ID Experts.

2. Control the cloud or it'll control you. Make it a point to fully understand what cloud service-level agreements mean in practice and then push for meaningful information on failover and disaster recovery practices used.Ē - Richard Santalesa, senior counsel, InfoLawGroup LLP.

3. Have a current breach response plan that is ready and tested. This will help pave the way for a well-executed response that can mitigate the financial, legal and reputational harm caused by a security incident involving patient information. - Marcy Wilder, partner and director of global privacy and information management practice, Hogan Lovellis.

4. Conduct small but focused risk assessments rotating control review on a monthly basis to continually understand and measure risk. Most importantly, have a plan to address the risk, through remediation, mitigation or risk transfer activities. - Chad Boeckmann, president and chief strategy officer, Secure Digital Solutions, LLC.

5. Immunize mobile devices against viruses that might steal patient data. - Dr. Larry Ponemon, chairman and founder, Ponemon Institute.

6. Attack your leadership team with phishing and other social engineering campaigns. Nothing raises awareness like catching people and correcting them on the spotóand it's a lot more interesting than the annual 30-minute online security training. - Michael Boyd, Director of Information Security Management, Providence Health & Services.

7. Use a checklist to evaluate periodically whether covered entities and business associates are in compliance with all privacy and security requirements. Sign and date the checklist to show that your organization is not guilty of "willful neglect" in complying with privacy and security laws. - Jim Pyles, founding partner, Powers, Pyles, Sutter & Verville, P.C.

8. Educate all staff to recognize applications, mobile devices and medical equipment that collect, contain or transmit patient information and/or biometric data; and train them to communicate the risk to those responsible for information security management. - Christina Thielst, FACHE, Vice President, Tower.

9. Decide how to handle the residual risk of a data breach, how much risk to accept, and how much, if any, risk to transfer through cyber insurance. - Christine Marciano, President, Cyber Data Risk Managers LLC.

10. Boards should ensure their organizations have robust, board-reviewed and approved security policies and procedures. - Larry W. Walker, president, The Walker Company.

11. "Big data" is a source of both the disease and the cure for privacy and information security symptoms. Currently, we have to deal with data minimization, but in the future, look for applications that may collect broadly, but protect against unauthorized disclosure or misuse very, very well. - Jon Neiditz, partner, Nelson Mullins Riley & Scarborough LLP.





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